Pest Management: Following in FSMA’s Footsteps

Your facility has most likely already implemented changes to abide with Food Safety and Modernization Act (FSMA), so now is a great time to check on how things are going as it relates to your pest management program.

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FSMA regulations mandate a shift from a reactive to preventative approach with a heavy emphasis on documentation. A pest management program should mirror this preventative aspect of FSMA. An integrated pest management (IPM) program will look at all factors that may affect a facility. It should be a targeted plan to not only deal with pests, but to prevent them and minimize their impact before they become a problem. The Preventative Controls for Human Food Regulation within FSMA requires that food plants have a written preventative pest management plan. Think about the last time you reviewed your overall IPM plan for your facility. Whether you have a pest management provider or perform your own in-house pest management, a review should be done on a yearly basis or when conditions significantly change.

Chances are that this IPM plan has been given a cursory glance at the end or beginning of the year, the date changed, and the program has continued similar to previous years. Take some time to really go through the plan, check the data and trend reports from the last 12-24 months, and see what’s working and what’s NOT working. Look for ways to make the entire program more effective and as preventative as possible. FSMA aims to prevent issues in the food system and the IPM program uses an entire toolbox of methods to do just that with pest issues.

In order to prevent, facility managers must do their best to predict where future infestations might occur. In other words, a program needs to stay one step ahead of the pests trying to invade your facility.

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Specifically, be prepared to answer anything that could be considered a “reasonably foreseeable biological, chemical, and physical hazard.” If something is contaminated, it no longer matters if it occurred naturally or intentionally. You must have documentation of your efforts. This doesn’t mean you need to scrap the food safety plan developed to meet Hazard Analysis and Critical Control Point (HACCP) standards, but you’ll need to make modifications with the help of a Preventive Controls Qualified Individual (another new requirement).

To ensure a food processing facility is meeting all of the requirements necessary, there are a few crucial steps that need to be taken.

Path to Compliance

Most pest management companies offer a free initial inspection, so take advantage of it! A full inspection of the facility should be done at least annually, even if you haven’t dealt with an infestation in the past year. You never know what pests could be lurking behind the scenes, especially if you’re keeping a lot of product stored in the facility. Be sure that pests haven’t compromised the packaging, or an infestation could spread quickly.

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After the initial inspection, staff training is a must. A few employees cannot be expected to monitor an entire facility but assigning all employees a specific role (based on their job function) can lead to quicker discovery of pest problems. Many pest management providers offer complimentary employee training programs to teach facility staff the signs of pest infestations. By doing so, individuals feel empowered to call out the danger signs, which will enable you to get ahead of pest issues faster. Think of it like this: If you’re coaching a soccer team, you wouldn’t send six players out at the start of a game when you’re allowed 11. All your employees are key players when it comes to detecting pests.

From there, remember that proactively preventing pests is a team effort between company leadership, employees, and the pest management professional. Throughout this process, it’s important to be on the same page, so communicate frequently. And don’t forget to record your efforts every step of the way—your hard work won’t matter unless you can prove it.

Of course, in order to determine what the pest issues are and if they are close to or at the threshold, you need to monitor. Monitoring and constant improvement will help a company remain compliant with FSMA guidelines. When doing so, careful documentation is key. While it can seem tedious, one shouldn’t overlook the value of monitoring and analysis as a management tool. Collecting data and putting it in context can be an effective way to prioritize pest control efforts.

A detailed analysis will account for normal seasonal cycles, deficiencies in maintenance, exclusion, sanitation and harborages, just to name a few. This analysis can also help improve pest control efforts by prioritizing areas needing attention, especially when your staff is limited by time or resources.

That’s why careful documentation is critical, as it will help demonstrate compliance with FSMA standards. It can also help you stay audit-ready at a moment’s notice.

The Paperwork

There are six key documents to keep on hand.

Food safety plan. The most important piece of documentation, the overarching food safety plan should be updated regularly. The plan should be a comprehensive document detailing all activities to ensure the safety of food during manufacturing, processing, packing and holding—and now—shipping as well. It should include a list of your facility-specific potential hazards, preventative controls and corrective actions taken to mitigate those risks, along with monitoring and verification procedures.

List of service changes. A food safety plan needs to be dynamic. But when modifications are made to meet the ever-changing needs of a facility, keep careful records of how and why the plans have changed. As you work to stay one step ahead of changing pest pressure, you’ll need to be agile and adapt your plan quickly. Document all changes made.

List of monitoring devices/traps. A food safety plan should include a map documenting all monitoring equipment, traps, and other devices used in the facility to reduce the likelihood of pests. Note the locations and activity levels of pests around each. A trend report from the collected data can help advise changes to the food safety plan. A pest management professional can help with this, as they should be noting activity each time they inspect the property. The historical data from pest monitoring devices and the corrective actions associated with any issues will show any third party that pest issues are taken seriously, which puts you in a great situation from the start. Monitoring devices also work as a warning system for developing pest issues, which is key to a proactive approach.

Annual assessments. Each year, review the food safety plan and current food safety program. Annual assessments note problem areas and help set goals for the coming year. It will help to demonstrate year-over-year improvement and show a long-term commitment to pest management. It’ll also demonstrate that pest issues in a facility aren’t lingering over time.

Sighting reports. Anytime a pest is spotted within the facility, it should be documented in a pest sighting log. The report should include information about the location of pests within the facility, who found them, and the number of pests spotted. Photo evidence helps with identification, so obtain a close-up picture of the pest(s) if possible. Ensure the pest is correctly identified by a professional and any corrective actions (if necessary) are documented. Record activity levels in the area over time to ensure the problem has been resolved.

Proof of training/certification. You know that your pest management professional is trained and certified, but a third party doesn’t. To demonstrate a provider’s expertise, keep on hand a valid license or certification document, written evidence of the pest management professional’s training, and documentation of internal training on IPM and Good Manufacturing Practices.

Case Study

Let’s bring all of this together with a case I dealt with recently. There was a large commercial bakery that started having a German cockroach issue. This was not one of the identified potential risks because it had not come up in the past. After thorough inspections, the problem was found mostly within a wall void. The employee breakroom was located on the other side of that wall. Once the cockroaches were treated, the food safety plan was updated to reflect the newly identified risk: employees bringing in cockroaches on personal items. Corrective actions were implemented: training of employees, better sanitation in the breakroom, and door seals from the breakroom to the processing areas were sealed. New thresholds were set and monitoring devices were put in strategic areas to monitor the area and verify that the corrective actions were working. The written IPM plan was also updated and everything was documented.

Your site has probably been in compliance with FSMA for a while but now is a great time to review to ensure the plans are still accurate and working. An IPM plan should be in line with all of FSMA’s requirements and ensure that your facility is preventing foreseeable pest issues.

Hartzer, the technical services manager for Orkin, is a board-certified entomologist and provides technical support and guidance across all Rollins brands in the areas of operations, marketing, and training. Reach her at mhartzer@rollins.com.

Food Quality & Safety (formerly Food Quality) is the established authority in delivering strategic and tactical approaches necessary for quality assurance, safety, and security in the food and beverage industry.